585. IRB Actions
Updated Oct. 4, 2019
This policy identifies the IRB Action categories available in IRBNet to document IRB review determinations, specifies the correlated IRB Review Types for each Action, and describes circumstances under which each Action will be used.
NOTE: RI opted out of using some IRBNet Action categories, as indicated below.
At the completion of administrative, exempt, and expedited or full committee IRB review of a project/package, RI staff will open the Review and Minutes page in the relevant package in IRBNet, and select or update the Action as specified below. The selected Action will auto-populate in IRB meeting agendas and minutes.
Action categories reflect the review outcomes (i.e., IRB determinations or decisions) for each package.
Investigators are provided documentation of all IRB Actions.
This Action only applies to projects and packages that do not require an assessment of the IRB criteria for approval. These actions are acknowledged by qualified RI staff under Administrative Review.
This Action applies to new projects, and to packages for continuing reviews, amendments; and Investigator Revisions reviewed as Expedited or Full Committee Review when the IRB or IRB member-reviewer (for expedited review) determines the information is complete and consistent, and all requirements for IRB approval are met, either in full or as allowed for non-exempt research meeting the criteria for review under the University’s IRB-Flexibility policy (IRB-Flex). Final approval of initial submissions is effective on the day that all conditions for approval have been determined to be met. The expiration date communicated to the investigator is the last date on which the research is approved. If approval is not renewed by the end of this date, the investigator will be notified in writing and must stop all research activities. Approval will normally expire within (1) year of the date on which the research is determined to meet the criteria for IRB approval, as outlined in federal regulations. However, the IRB may decide at the time of review that, due to concerns regarding the study or the investigator, the study in question should be reviewed on a more frequent than annual basis. This condition may be imposed at any time during the life of the study while under IRB review. If concerns are eventually found to be unwarranted, the IRB may opt to return the study to an annual review schedule.
Approved with Conditions
This Action applies to new projects, and to packages for continuing reviews and amendments reviewed as Expedited or Full Committee Review when the requirements for IRB approval have been met but minor or directed changes are required to secure approval. Approval is conditional upon the stipulations being satisfied. The conditions for approval and the time frame (if any) within which they must be met are clearly stated in the letter to the Investigator. The date of approval is the date the conditions were determined to be met. If the conditions are not met, approval may be withdrawn. This Action also applies if minor or directed changes remain following review by the convened IRB of Revisions packages submitted for review by investigators. (For information about minor revisions, see revisions in IRB Policy Manual definitions.)
NOTE: Conditional approval is not given when revisions are necessary to confirm the regulatory requirements for IRB approval are met. Requests for such substantive revisions (e.g., clarifications, explanations, additional information, external committee approval) are Deferred.
When the IRB approves research with conditions, the adequacy of the investigator’s response/follow-up package is confirmed via Expedited Review by the IRB Chair, Primary Reviewer, or a designated IRB member (including RI staff who are voting members of the IRB).
Closure requests are processed under Administrative Review for either of the following circumstances:
- Following an investigator request to close a project, RI staff determine that the project may be closed because all human research activities have ceased or the remaining activities are limited to analysis of anonymized data (i.e., data do not contain any information that could be used to identify an individual and master code lists have been destroyed).
- Following expiration of IRB approval (i.e., investigators did not submit a renewal request in sufficient time to allow IRB review before the expiration date), RI staff (via IRBNet) to notify the PI that research activities must cease because IRB approval for the project expired.
This Action applies to new projects, continuing reviews, and amendments reviewed as Full Committee Review when the convened IRB is unable to determine that requirements for IRB approval have been met and requests substantive revisions. (For more information about substantive revisions, see revisions in IRB Policy Manual definitions.)
Investigator responses to deferrals are submitted as a new package under Revisions type for review at a subsequent IRB meeting unless the convened IRB when deferring approval, determines and documents that the research is limited to one or more DHHS categories of research that may be reviewed by the IRB through an expedited review procedure. In the latter case, the convened IRB will specify who may review the investigator’s response to the requested revisions (e.g., IRB Chair, Primary Review, or other designated IRB member).
This Action applies to new projects reviewed under Exempt Review when a qualified IRB member determines the proposed research is exempt from IRB review under DHHS exempt categories 1-6 or under IRB-Flex, as Flex-Exempt.
NOTE: An IRB member may determine a project submitted for Expedited Review is exempt. The reviewer will document this determination in IRBNet. RI staff will update the Review Type to Exempt Review and select Exempt for the Action.
This Action is used when RI staff request information to proceed or finalize IRB review, and when Approved with Conditions and Deferred do not apply.
This Action is not used. Here are the preferred Actions in which the IRB may require modifications:
- Following IRB review, information is required that is not essential for the IRB to determine the requirements for approval have been met: RI staff select Approved with Conditions.
- Following IRB review, information is required that is essential for the IRB to determine the requirements for IRB approval have been met: RI staff select Deferred.
This Action (AKA: Disapproved) only applies to new projects or substantive amendments reviewed as Full Committee Review when the convened IRB determines the research does not meet the criteria for IRB approval and significant changes would be required to protect participants.
To simplify internal processes and minimize use of resources, this IRB Action is not used. Instead, all determinations that a project does not constitute research or does not involve human subjects are categorized as Action Research – Not HSR.
Research – Not HSR
This Action applies to new projects submitted for determinations of human subject research reviewed as Administrative Review when qualified RI staff determine
- a proposed activity, program, or project does not constitute research as defined in the regulations at 45CFR46.102(d);
- a research project does not involve human subjects as defined in the regulations at 45CFR46.102(f); or
- the University or a University or affiliate research is not engaged in non-exempt human subject research.
See IRB Policy Manual definitions for human subject, research, and engaged in non-exempt human subjects research.
NOTE: An IRB member may determine a project submitted for Exempt or Expedited Review does not constitute research with human subjects. The reviewer will document this determination in IRBNet. RI staff will update the Review Type to Administrative Review at the same time she/he selects Research – Not HSR for the Action.
Tabled without Action
This Action applies only to projects/packages reviewed as Full Committee Review when it is necessary to document that no action was taken during a convened IRB meeting (e.g., the IRB was unable to review a project/package due to lack of quorum). This is a temporary Action. Review will resume using the package that was tabled.
This Action applies to a problem report reviewed as Full Committee Review when the convened IRB confirms a preliminary determination via Administrative Review by the IRB Chair or the RI Director, or Expedited Review by a subcommittee of the IRB that
- a temporary cessation is warranted for one or more aspects of an active IRB-approved study, or
- the research must be immediately suspended.
NOTE: Depending on the severity of the problem or need for immediate action to protect human subjects or others, research activities may be suspended immediately following the preliminary recommendation for suspension. However, the Action is not updated until the Suspension is confirmed following Full Committee Review.
This Action applies to a problem report reviewed as Full Committee Review when the convened IRB confirms a preliminary determination via Administrative Review by the IRB Chair or the RI Director, or Expedited Review by a subcommittee of the IRB that immediate termination is warranted for an active IRB-approved study.
NOTE: Depending on the severity of the problem or need for immediate action to protect human subjects or others, research activities may be terminated immediately following the preliminary recommendation for termination. However, the Action is not updated until the termination is confirmed following Full Committee Review.